Incident Report

Subject:            NFPA & OSHA Quick Card Compares NFPA 704 “diamond” and OSHA GHS labels

Date of Email report:   Wed 07/08/2013

Report Detail:

When OSHA announced last year that it was updating its Hazard Communication Standard to include the adoption of the Globally Harmonized System of Classification and Labelling of Chemicals, many companies and emergency responders asked “How will this impact NFPA 704”?  NFPA 704, Identification of the Hazards of Materials for Emergency Response, uses a combination of colour coding and numbers to describe a hazard’s severity, and provides a simple, readily recognized, and easily understood label to assist those who are responding to an emergency such as a fire or spill. OSHA’s revised Standard, known as Hazard Communication 2012 or HC2012, is a workplace chemical information system established primarily to provide information and safe work practices for those working with chemicals on a routine basis through the use of labels, Safety Data Sheets (SDSs) and training.  

The concern is that the HC2012 standard incorporates a numerical rating system that appears to be similar to NFPA 704 rating system, however the severity rating on the two standards are inverted.   NFPA 704 uses a numerical of 0-4 with 4 indicating themost severehazard.   Hazard Communication 2012 uses a numerical rating system for classification of chemicals between 1-4 with a 4 rating indicating the least severe hazard.  The inverse numerical rating between the two systems is primarily what creates the concern.

To address this concern, NFPA has been working with OSHA over the past year to promote awareness of the differences between the two systems. It should be noted that OSHA does not necessarily see a conflict between HCS and NFPA 704.  OSHA has indicated that the GHS numbers are not relative ratings of hazards but are used for the purpose of classifying hazards into categories for proper labelling and training information. The numbers for GHS will be placed on the SDS but are not required to be on labels.  

Recently OSHA and NFPA worked together to develop a “Quick Card” showing the differences between the two systems.The Quick card can be found on the NFPA Document information page for NFPA 704  at the bottom of the page under “Additional Information”. Or you may go directly to the Quick Card.   The card can be downloaded and laminated as a two sided document that can be used for easy field reference. 

The NFPA Technical Committee on Classification will continue to assess the impact of GHS incorporation into OSHA’s HC2012 standard.  In the meantime, there is no immediate plan to change the existing NFPA 704 system.   

Additional Documentation:

NFPA704_HC2012_QCard